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~~""~° ~ $~ ~. • Attached as "Guideline Table 1" is the Wyoming Department of Environmental Quality's (DEQ) suitability ratings for topsoil medium. This suitability guide presents various soil characteristics and associated parameters slightly different than what is presented in Table Z.3-1. The Division believes the guideline established by the DEQ should be utilized rather than the guideline as presented on Table 2.3-1. P&M should revise Table 2.3-2 (Evaluation of Soil Reconstruction Material) to reflect DEQ guidelines, and evaluate whether *„his substantially affects stripping and/or replacement depths. IT WAS MUTUALLY AGREED TO BY MLRD AND P&M TO DELETE THI5 COMMENT. NO CHANGE IN THE PERMIT TEXT IS REQUIRED BY THIS COMMENT. III. Vegetation - 2.04.10 Information pertaining to the vegetation studies and the criteria for determining reclamation success is located in the original permit application document. The baseline vegetation information in this document remains adequate since P&M plans on mining lands previously permitted and inventoried. The methods for determining revegetation success are presented in Appendix 2.4-B of this document. A review of this appendix raised the following concerns. • A. The regulations pertaining to statistical confidence levels have been revised. The regulations now specify that cover and production of the revegetated area shall not be less than 90 percent of the cover and production of the reference area with 90 percent statistical confidence. The regulations no longer address a reduced (i.e.: 80 percent) statistical confidence for woody vegetation communities. Therefore, P&M needs to revise this appendix to reflect current regulations pertaining to statistical confidence. THE REVISED PORTIONS OF APPENDIX 2.4-B ARE ENCLOSED AND MAY BE DIRECTLY INSERTED INTO THE PERMIT A5 PART OF APPENDIX 2.4-B. B. The use of a reference area for comparison against revegetated areas is acceptable for herbaceous cover (4.15.8(3)), for herbaceous production (4.15.8(4)), and for woody plant density (Rule 4.15.8(7)). However, P&M has not committed to a technique for determining species diversity (Rule 4.15.8(5)). P&M should submit a plan addressing revegetation success criteria for these two parameters. The Division would suggest a species/life form composition approach similar to that approved for other mines in northwest Colorado. A TECHNIQUE TO ADDRESS REVEGETATION SUCCESS CRITERIA IN TERMS OF SPECIES DIVERSITY HAS ALREADY BEEN MUTUALLY AGREED TO BY MLRD AND P&M. INFORMATION REGARDING THIS AGREEMENT IS ENCLOSED AND MAY BE • SUBSTITUTED DIRECTLY INTO THE PERMIT AS PART OF APPENDIX 2.4-B. C. P&M does not address when monitoring of revegetated areas will occur. A more extensive review of the application document reveals that P&M will monitor in years nine and ten of the liability period